Authors: Sydney Shearer (Senior Manager, Accountancy Licensing Library) & Elizabeth Wolfe (NASBA Regulatory Counsel)
Posted: Oct. 6, 2020

On July 1, 2020, a new federal regulation went into effect that will impact how Title IV eligible programs communicate with students about their curriculum. 34 CFR 668.43, which encompasses rules about institutional information, has been updated to include numerous new professional licensure disclosure parameters. This regulation will likely have a significant impact on accounting programs across the United States.

If an institution offers a program designed to meet educational requirements for a specific professional license or certification, required for employment in an occupation or is advertised as meeting such requirements, they must now provide more specific disclosures to students. Programs include majors geared towards the Certified Public Accountant (CPA) license. These disclosures must include information regarding whether completion of such program would be sufficient to meet licensure requirements in a state for that occupation. More specifically, this regulation requires an institution to create a list of all states for which the institution:

  • has determined that its curriculum meets the state educational requirements for licensure or certification;
  • has determined that its curriculum does not meet the state educational requirements for licensure or certification; and
  • has not made a determination that its curriculum meets the state educational requirements for licensure or certification.

Institutions are also required to notify prospective students if the curriculum does not meet state requirements or if the institution has made no determination where the perspective student is located prior to enrollment in the program. This allows the student to make an informed choice prior to making a financial commitment with the Institution. Additionally, institutions must inform enrolled students within fourteen (14) calendar days of the institution’s determination that the curriculum does not meet state requirements where the student is located. Provisions regarding penalties for institutions that engage in substantial misrepresentation to students, specifically including professional licensure information, are outlined in the new regulation as well. Substantial misrepresentation includes, but is not limited to, false, erroneous or misleading statements.

While compliance with this new federal regulation may seem daunting, the National Association of State Boards of Accountancy (NASBA) offers several tools, which may assist academic institutions. NASBA’s Accountancy Licensing Library (ALL) is a central database of licensing requirements for the 55 U.S. jurisdictions. The ALL was designed to help simplify the confusing licensing process for aspiring CPAs and has long been used by academic advisors across the county to help guide students through the next phase of their career.

The ALL contains two sections, a research tool and state-by-state licensing details.* With the ALL Research Tool, users can quickly and easily determine high-level, state-to-state requirements for the CPA Exam and CPA license, by selecting criteria and running an exportable report. The bulk of the database is made up of licensing requirements and procedures for each state. Here, state rules, regulations, procedures and policies are written in a simple, narrative format that is easy to understand and is reviewed and updated on a regular basis.

This tool is your one stop resource for CPA licensing requirements. Rather than visiting each state board website, the ALL provides all details in one place, making your professional licensure disclosure compliance plan much less painful.

NASBA offers complimentary accounts to accounting program chairs at colleges and universities, as well individuals working to prepare professional licensure disclosures for their institution. Visit to learn more about ALL and to sign up for a complimentary academic subscription by emailing [email protected].

*The Accountancy Licensing Library (ALL) is intended for informational purposes only. Please consult the complete Terms and Conditions prior to using the ALL as a resource.

Other Helpful NASBA Resources

In addition to the ALL, educational institutions may also benefit from other products and services offered by NASBA, aimed at assisting students and professionals as they enter each stage of the CPA lifecycle. The following are two that may be helpful when students are selecting states to sit for the Exam and become licensed.

Undecided Evaluation service

NASBA’s Undecided Evaluation service aims to guide students with international education along a clear path to the CPA Exam, offering a comprehensive understanding of how their education is viewed by the U.S. Boards of Accountancy. The Undecided Evaluation will equate the student’s international education to the U.S. equivalence. The evaluation will suggest up to three jurisdictions that should provide the best opportunity to qualify for the CPA Exam. The student can then use the suggestions to apply for a jurisdiction-specific International Credential Evaluation, which is needed to apply for the CPA Exam.

CPA Mobility

With statutes approved in almost all of the 55 U.S. jurisdictions, and pending in most of the rest, mobility has become a reality for CPAs and accounting firms from coast to coast. Mobility is a practice privilege that generally permits a licensed CPA in good standing from a substantially equivalent state to practice outside of his/her principal place of business without obtaining additional licensure. With, CPAs can learn whether mobility applies to their specific situation and whether firm registration or other paperwork is required – all within four simple clicks. Available via mobile phone, provides a wealth of information at your fingertips.

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